Was asked a question regarding 4.13(a)(2) exempt CPO, a.k.a Small Pool Exemption. The NFA statement is: Total gross capital contributions in all pools operated or intended to be operated do not in the aggregate exceed $400,000 The question was whether that means total AUM of less than $400K or just total initial capital contributions of $400K. I didn't know the answer. The wording on the statement suggests that it is the latter, but in my research I came across a few statements implying the former. Admittedly, these were from CPAs who would benefit from selling a more expensive 'non-exempt' package. Thanks guys.